TMI Blog2015 (4) TMI 17X X X X Extracts X X X X X X X X Extracts X X X X ..... lls within the aforesaid block period, the assessee wants the benefit of this amendment for the entire block period of ten years, i.e., 1.4.1986 to 31.3.1996. Such a plea is unacceptable on the face of it. It is clear that amendment is substantive in nature, which is so mentioned in the explanatory notes of amendments as well. Once we find that the amendment is substantive in nature, it cannot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee herein is engaged in production and distribution of motion pictures mainly in Tamil language. There was a search under Section 132 of the Income Tax Act, 1961 (hereinafter referred to as the 'Act') at the business premises of the assessee during which certain book of accounts were seized. Consequent to the search, proposal was made for assessment for the block period of ten years 1.4. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessment year in question. Feeling aggrieved by the order of the Appellate Tribunal, the appellant filed appeal before the High Court. The High Court did not accept the contentions of the appellant which were based on the amended Section 158B(b) in Chapter XIVB of Finance Act, 2002 and dismissed the appeal. Questioning the validity of the aforesaid judgment of the High Court, the present appeal h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... A(3) were amended with effect from 1.4.1996. With this amendment, in cases where the cash payment is made in excess of ₹ 20,000/-, disallowance is limited to 20% of the expenditure. Since the date of the amendment falls within the aforesaid block period, the assessee wants the benefit of this amendment for the entire block period of ten years, i.e., 1.4.1986 to 31.3.1996. Such a plea is unac ..... X X X X Extracts X X X X X X X X Extracts X X X X
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